ELR Citation: ELR 20427
No(s). 84-5390 (3d Cir. Apr 24, 1985)

The court rules that under §505(b)(1) of the Federal Water Pollution Control Act (FWPCA), an Environmental Protection Agency (EPA) administrative enforcement proceeding is not a "court" action barring commencement of a citizen enforcement suit. Applying its analysis in an earlier case under the cit...